Subject: File No. 4-497
From: Grady E Means
Affiliation: Chairman, Financial Market Solutions

April 2, 2005

To the SEC

Sarbanes-Oxley does not improve controls or related processes, and, as such, does not lower investor, corporate, or market risk. Audit processes will continue to review very small samples and generally not catch key controls failures until well after they have occurred. Companies and their auditors will need to better use technologies to really improve financial reporting and lower risk. New continuous controls and continuous audit technologies are the only approach that truly addresses this problem. The articles on and articles such as that which appeared today in the Sarbanes-Oxley compliance journal entitled Is Continuous Auditing Right for You? at suggest the answer.